Court Rules Against Using Identical Transactions Alone for Comparables in Transfer Pricing Case, Citing Tata Brand Influence.

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....TP Adjustment - exclusion of comparables - submission that "an identical transaction being conducted in an uncontrolled manner” overlooks the effect of the Tata brand on the performance of the impugned comparables - The mere fact that the transactions were identical was not either a sole or a reliable yardstick to determine the apposite choice of comparables - excluded....